Penn-Dixie Steel Corp. v. Commissioner
United States Tax Court
1. In 1968, Union and Continental entered into an agreement to form a new corporation, Phoenix. Continental contributed cash and received 50 percent of Phoenix's stock. Union contributed the assets and liabilities of Old Phoenix, one of its divisions, and received 50 percent of Phoenix's stock and a debenture of Phoenix.
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1. In 1968, Union and Continental entered into an agreement to form a new corporation, Phoenix. Continental contributed cash and received 50 percent of Phoenix's stock. Union contributed the assets and liabilities of Old Phoenix, one of its divisions, and received 50 percent of Phoenix's stock and a debenture of Phoenix. Union was given the right to put its stock in Phoenix to Continental on set terms during the period Aug. 1, 1970 to July 31, 1971, and Continental was given the right to call Union's stock in Phoenix on the same terms during the period Aug. 1, 1971 to July 31, 1972. Union…
1Opinion of the Court
Tannbnwald, Judge:
Respondent determined a deficiency of $574,795 in the Federal income tax for the taxable year ending January 1,1972, of petitioner’s predecessor.
The issues remaining for our decision are: (1) Whether a 1968 transaction between petitioner’s predecessor and another corporation constituted a sale with a deferred payment, entitling the predecessor to a deduction for imputed interest under section 483;1 and (2) whether the predecessor’s failure fully to comply with respondent’s regulations precludes qualification for rapid amortization of pollution control facilities under…
2Cases cited32 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Bingler v. JohnsonSupreme Court of the United States · 1969
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Reaver v. CommissionerUnited States Tax Court · 1964
- Merrill v. CommissionerUnited States Tax Court · 1963
27 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Derr v. CommissionerUnited States Tax Court · 1981
- Tipps v. CommissionerUnited States Tax Court · 1980
- John H. Young and Carolyn J. Young v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1986
- Spector v. CommissionerUnited States Tax Court · 1979
22 more not listed; retrieve them via the Exa API.